Facebook v. CCPA

Facebook v. CCPA

Facebook v. CCPA

After everything Facebook went through with the Cambridge Analytica scandal and the massive lawsuits currently pending over violations of GDPR,  Facebook decided that California’s new privacy law, CCPA, just doesn’t apply to them…really Facebook??

So you are asking me…Emily, what is CCPA..sorry. Let’s get to that. The California Consumer Privacy Act or CCPA went into effect in California on January 1, 2020. However, the State of California is giving companies a 6-month implementation ramp so enforcements and lawsuits haven’t started flying just yet (but they will…..). To understand some of the criticism of this law is a steaming hot mess, you need to understand a little of where it comes from.

California’s Propositions… a whole new world. 

California is one of a few states that has a ballot proposition system. Every election year anyone with enough money (ahem…signatures), can include a proposition that can be voted into law. I won’t even get started on some of the poorly written messes to come out of the propositions. The Consumer Privacy Act of 2018 was backed by a real estate developer and gained enough support and signatures to be included on the ballot, however, the proposition was fairly strict and restrictive.  Naturally, the California legislature decided to rush through the California Consumer Privacy Act of 2018, fondly referred to as CCPA. The legislature rushed this through in exchange for the proposition being dropped off the ballot. 

This agreement has left consumer groups frustrated that the bill doesn’t go far enough and business frustrated with the most restrictive and unclear consumer privacy law in the country. Don’t worry though, at least 10 other states are considering similar legislation. Eventually, I believe there will be a federal law similar to GDPR so businesses aren’t complying with different privacy laws in different states.

Right…so what is CCPA actually. Well, it regulates how companies can collect, distribute, pass along to other companies and allows consumers more control to see and direct what happens with the information companies do have. To that end, Facebook does have a form for California residents to request what data Facebook has on them or to remove that data, so that’s something.

Under CCPA companies who are required to comply must, and this is my favorite part, must place a link on the front page of their website that says “do not sell my personal data”. That is where residents can access the data that companies have about them. Proponents of CCPA are optimistic that when companies implement CCPA they will think its such a pain in the ass to separate California residents from everyone else that they will just allow everyone accesses to their data. 

What Businesses Does CCPA Apply to?

There are of course rules about what companies are required to comply;  

  1. Businesses that make more than  $25 million in annual gross revenue. 
  2. Businesses where more than 50 percent of their revenue comes from the sale of California residents’ data.
  3. Businesses who process the personal data of more than 50,000 California reside.

The problem comes in with this pesky little word ‘sale’,  Facebook contends that as a company it does not sell data. In Facebooks Q4 earnings from 2019, the company made 16.9 Billion (Yes with a B), in ad revenue.  So how does CCPA define ‘sale’…  

So what’s a Sale?

CCPA defines Sale as: ‘“Sell,” “selling,” “sale,” or “sold,” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.” -CCPA

Given that definition of sell, it’s hard to comprehend that Facebook who made over 16.9 Billion on selling ads doesn’t ‘sell’ data. Facebook argues that because they are using the Pixel they are not selling data. However, the ads are valuable because of the DATA! Business are buying ads because they can specifically target their ideal individuals. 

So where we stand now Facebook is arguing that they have basically complied and that the law doesn’t really apply to them anyway. I would love to hear your thoughts on this level of BS.…let me know your thoughts on Instagram @TheEmilyDBaker.

If you want to hear more of my thoughts on Facebook v. CCPA  Episode 16 of Get Legit covers it! Don’t forget to drop a review if you love it.

 

Emily D. Baker, Esq.

Emily D. Baker, Esq.

Badass Lawyer for Online Business

Emily has been running business for 15 years and has ove 13 years of legal experience. She spent 10 years at the Los Angeles County District attorney's office where she truly learned to be a solopreneur. Emily has built her consulting and speaking business from the ground up, in her garage jamming out to 90's music. She specializes in no BS practical advice for the starting and scaling online entreprenur. Emily will tell you what the business gurus can't in a way that is both hillarious and empowering.

Questions for Emily? Just Ask...

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The Sunday Riley FTC Settlement

The Sunday Riley FTC Settlement

What is the Sunday Riley FTC settlement?

The Sunday Riley FTC settlement gives us a lot of insight into the direction the FTC is taking their action towards false advertising claims, and some amazing tea.  I am not going to lie, I love it when the FTC isn’t afraid to just lay someone out. That said the Sunday Riley FTC settlement doesn’t require Sunday Riley to admit fault, so everything stated is alleged. However, alleged with quite a bit of actual quotes, and evidence, but still, fault has not been admitted by Sunday Riley.

So what is Sunday Riley alleged to have done?

The FTC Alleges that Sunday Riley violated the law by: 

  1. Making false or misleading claims
  2. Failing to disclose that the reviews were written by her and her employees

It’s further alleged that between 11-2015 & 8-2017 managers including Ms. Riley herself posted reviews of their products on the Sephora website using fake accounts (presumably to hide their identity) and requested other employees to do the same thing. But it doesn’t just end there.  Because Sephora is a pretty savvy company. Sephora removed the reviews. The Sephora website recognized the reviews had all come from one IP address. When numerous reviews on the same product come from one IP address it’s no wonder it’s flagged in the Sephora system. Fake reviews are a raising concern online and I appreciate that Sephora is attempting to combat that. 

Oh, but there is TEA!

The Sephora websites’ fraudulent review system didn’t stop Sunday Riley…. NOPE. In the Sunday Riley FTC Settlement press release the FTC quotes a company manager “They got an Express VPN account to allow us to hide our IP addresses and location when we write reviews”. Seriously…the balls. It seems Sunday Riley as a company got a VPN, or Virtual Private Network service to mask their IP address to game the Sephora system so they could continue leaving bogus reviews.

The press release goes on to quote an email from  Ms. Riley to her team where she directed her staff to “create three accounts on sephora.com registered as different identities, and then leave 5-star reviews when reviewing Sunday Riley skincare products and dislike negative reviews “if you see a negative review — DISLIKE IT’ Ms. Riley went on to say “after enough dislikes, it is removed. This directly translates into sales’. But that isn’t all, according to the FTC, that email also included step by step instructions to her team to use the VPN to set up new personas and hide their identities!!

In the Sunday Riley FTC settlement, it was agreed that;

  1. The company barred from reviewing it’s on products online 
  2. Must instruct employees never to review a product without disclosing their relationship to the company
  3. The settlement is intended to ‘ensure the respondents do not engage in similar allegedly illegal conduct in the future

Not all of the FTC commissioners agreed with the Sunday Riley Settlement. Commissioner Chopra joined by Commissioner Slaughter (no I didn’t make that up but Slaughter is baller last name.) dissented, with the fact that the settlement was too lenient. The dissent continued arguing that the settlement will not deter other firms from ‘engaging in fake review fraud, which is a growing issue in the online space.’ They took issue with how long this fraud was going on, yea…almost two years of systematic fraud, and fraud clearly for the purpose of financial gain.

The commissioner stated in sum “ [t]his statement sends the wrong message to the marketplace, dishonest firms may come to conclude that posting fake reviews is a viable strategy, given the proposed outcome here. Honest firms, who are the biggest victims of this fraud, may be wondering if they are losing out by following the law.” Honestly, I agree with them. 

You may be wondering how the FTC even finds out that a Company like Sunday Riley is perpetrating this type of scheme….well the way a lot of government agencies find out about things. An ex-employee made a comment about it.  According to a Buzzfeed article a former employee of Sunday Riley posted on Reddit stating that the company was using fake reviews and that the company encouraged people to make positive reviews. The thing is that in making reviews you have to disclose if you have a relationship with the company financial or otherwise.

Companies have to understand the rules in the online space and must advise their employees of those rules. False Advertising is a crime, failing to disclose a relationship is a crime. Companies cannot ignore how the growth of social media can affect them, and companies will do well to remember that there is a fine line between ethical advertising and ending up like Sunday Riley.

I would love to hear your thoughts on this settlement and the actions of Sunday Riley…let me know your thoughts on Instagram @TheEmilyDBaker.

If you want to hear more of my thoughts on the Sunday Riley FTC settlement and similar cases Episode 15 of Get Legit covers it! Don’t forget to drop a review if you love it.

 

Emily D. Baker, Esq.

Emily D. Baker, Esq.

Badass Lawyer for Online Business

Emily has been running business for 15 years and has ove 13 years of legal experience. She spent 10 years at the Los Angeles County District attorney's office where she truly learned to be a solopreneur. Emily has built her consulting and speaking business from the ground up, in her garage jamming out to 90's music. She specializes in no BS practical advice for the starting and scaling online entreprenur. Emily will tell you what the business gurus can't in a way that is both hillarious and empowering.

Questions for Emily? Just Ask...

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Trademark, Cocaine Santa & Santa’s Sack.

Trademark, Cocaine Santa & Santa’s Sack.

Santa Trademarks 

From Santa Poo to Cocaine Santa there is a Santa Trademark out there that may just make you laugh. In the Christmas episode of Get Legit Law & Sh!t I explore the hilarious world of Santa Trademarks. 

Ok, What are trademarks?

First, some of the Trademarks I discuss are applications for trademark and are not, yet, registered Trademarks…however, if you are here for a giggle I figured you wouldn’t mind. If you are looking for a better understanding of Trademark law, this is more of an overview.

Trademarks are meant to protect consumers. The goal is for a consumer buying a good to be able to identify the source of that item and to eliminate confusion over similar products. Take Coke and Pepsi. Both have various trademarks protecting the name and branding on their cans and bottles. You wouldn’t pick up a red and white can and be confused that it didn’t taste like Pepsi. You know it’s a Coke.  Speaking of coke…..

Cocaine Santa

I missed the moment that Cocaine Santa took the world by storm. I was unaware that this sweater (see image) was the number one seller on Amazon and that it was pulled from various online retailers…like Walmart. There are numerous news stories about the Cocaine Santa sweaters, and possibly the most coverage came from it being pulled from Walmart Canada’s website. I would love to know what you think of Cocaine Santa…so leave me a comment. That said, I can totally see why someone decided to trademark this. What I didn’t understand is why it’s trademarked for onesies? Maybe to just corner the market, or just round out that entire clothing registration category there. But I will be interested to see if next holiday season there are Cocaine Santa onesies….I guess there is a market for everything?

Santa Poo

From Cocaine Santa we have to talk about Santa Poo…at first I thought this was a toy of some kind, like that Unicorn Poo that’s everywhere in Target. I assumed some kind of Red, White and Green bearded Poo Emoji..or something like the image below which is what you will find if you google Santa Poo Emoji. But when I saw the complimentary Trademark filing I knew. The other Trademark is ‘Because even Santa has to go” I know it was the folks at  Poo~Pourri. Their ad campaigns are always clever, and the Tag line was so on-brand for them I knew it was a Santa  Poo~Pourri, but I hadn’t been able to find it in stores….next year I guess.

*Santa Poo Emoji from redbubble.com
* Santa Poo~Purri from their marketing material

 

Santa’s Sack

Those aren’t the only Trademarks that gave me a giggle while searching for Santa Trademarks. The wide variety of Santa Sack trademarks, some predictable, some not so much…was amazing.  I am only bummed that I couldn’t find the Santa’s Sack candle torch….but while searching for it I did come across a Santa’s Sweat Sack candle on Etsy and that counts for something. If only I could find the Santa’s Sack torch to light Santa’s Sweaty Sack with….but I digress. I can’t even begin to imagine what’s in Santa’s Suprise Sack….but maybe next Christmas it will be the toy to find.

 

Santa Slime

From Santa’s Sack, I slipped into the internet and found a wide variety of Santa Slime. While I couldn’t locate the product sold by the trademark registrant, Etsy is again the gift that keeps on giving. Etsy gives us Santa Slime, Santa’s Cloudy Slime, Santa Belly Slime and a bunch of other dirty sounding shit…..like a Santa Snowball. Look, if you have seen Clerk’s you know why this is funny. My biggest regret is that I don’t have anymore white elephant parties to attend, but next year everyone is getting Santa Belly Slime with a Santa’s Sweaty Sack candle.

 

I hope that wherever and whenever you find this post and this episode of Get Legit it brings you a little joy and a lot of laughs. I appreciate you and hope that you have a blessed and joyful holiday season however you celebrate….no judgment here! 

 

Emily D. Baker, Esq.

Emily D. Baker, Esq.

Badass Lawyer for Online Business

Emily has been running business for 15 years and has ove 13 years of legal experience. She spent 10 years at the Los Angeles County District attorney's office where she truly learned to be a solopreneur. Emily has built her consulting and speaking business from the ground up, in her garage jamming out to 90's music. She specializes in no BS practical advice for the starting and scaling online entreprenur. Emily will tell you what the business gurus can't in a way that is both hillarious and empowering.

Questions for Emily? Just Ask...

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California’s Freelance Apocalypse has begun.

California’s Freelance Apocalypse has begun.

California begins the Freelance Apocalypse

You have likely heard of California’s AB5 by now. You know the new law that has changed the test for who qualifies as an independent contractor making an estimated 1 million freelancers employees as of January 1, 2020, according to an International Business Times article. Most assume that this law was ushered through the California legislature with little through for the fallout. Which, seems to be the case, but it was the law of the land before the bill was signed due to a California Supreme Court decision in the Dynamax case.

That decision changed the law, the rather rushed bill just applied further parameters, fines for lack of compliance, more bureaucracy and carved out exceptions for some (lawyer, doctors, realtors, HR professionals), and left many others wondering what the fu$k they are supposed to do now (fitness trainers, truckers, pilates instructors, musicians, photographers, a large majority of writers). 

I work with online business owners varying from service providers to the course and content creators to straight-up creatives. All of these businesses thrive and survive on collaborative work with independent contractors. Most of my clients are moms who opted for more freedom for their family and took to the internet to carve out a living. Now, these same businesses that allow women to make choices about their child care and children’s schooling are facing either an increased workload, increased overhead or potentially the closing of their business. 

I have been fielding calls for weeks from freelancers and business owners alike asking the same question ‘what do I do now’. Out of state businesses are choosing to cut ties with California freelancers. Businesses within California are also ending their relationships with freelancers, requiring them to either apply for positions as employees (where they will get paid less and lose a lot of the tax benefits of running your own business), or their contracts are just ended.

The thing that hasn’t been considered is how much this hurts freelancers who love working that way. As a freelancer you set your own hours, take on work as you choose to, experience the tax benefits that come with owning your own business and own your intellectual property (if your contract is written well by an awesome lawyer like me). As an employee, your intellectual property belongs to your employer. A consequence that obviously wasn’t considered by the legislature. 

The termination of contracts for hundreds of Vox Media freelancers this week is the beginning of a landslide for freelancers in California. I have one question for you guys…..where are we moving??

If you need more information on AB5 and how it may affect you and your business I have other resources on the topic.

RESOURCES

Get Legit Law & Sh!t Podcast covering the topics

Blog Article “AB5 and YouTube Creators”

The Independent Contractor Guide is coming soon and you can sign up for it below. 

If you have a community that needs this information I am here to help. Shoot me an email to hello@emilydbaker.com. I am happy to talk to your community, podcast, or channel about how to Get Legit™.

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Emily D. Baker, Esq.

Emily D. Baker, Esq.

Badass Lawyer for Online Business

Emily has been running business for 15 years and has ove 13 years of legal experience. She spent 10 years at the Los Angeles County District attorney's office where she truly learned to be a solopreneur. Emily has built her consulting and speaking business from the ground up, in her garage jamming out to 90's music. She specializes in no BS practical advice for the starting and scaling online entreprenur. Emily will tell you what the business gurus can't in a way that is both hillarious and empowering.

Questions for Emily? Just Ask...

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What Content Creators Must Know about COPPA.

What Content Creators Must Know about COPPA.

If you are feeling stressed and confused about YouTube, COPPA, Content Creation and the FTC you are not alone. The recent and historic fine levied on YouTube and parent company Google by the FTC is a clear indicator to content creators on all platforms that winter change is coming. I have gotten quite a few questions about this because I am a lawyer and a content creator..so let’s talk about it a bit more.

What can content creators do?

First, the fact that you are paying attention is a huge plus. You are taking action to make sure that your content isn’t going to create problems for you. If you are on a non-monetized platform, pay attention to the rules regarding collecting or encouraging the collection of information. If you are on YouTube then you are aware that you need to start indicating if your content is made for children and understand what content could be considered to have an ‘intended audience’ of children under 13. 

Is your content ‘child-oriented’?

The FTC published a Six-Step Compliance Guide in 2013. Despite this YouTube asked the FTC for further clarification last week. This is likely because YouTube is getting screamed at by content creators who have no idea how to comply and YouTube is doing its best to pass all the responsibility for compliance along to creators. This despite the fact that the FTC listed how YouTube must comply, and the fact that COPPA was enacted into law before YouTube even existed and they have blatantly ignored it for over 13 years…but I digress…

‘Child Oriented’ or whether the ‘Intended Audience’ is under 13 is determined by the FTC by evaluating the following factors. 

  1. The subject matter
  2. Visual content
  3. Use of animated characters or child-oriented activities & incentives
  4. The kind of music or other audio content
  5. Age of models
  6. Presence of child celebrities or celebrities who appeal to children
  7. Language or other characteristics of the site
  8. Whether advertising that promotes or appears on the site is directed to children &
  9. Competent and reliable empirical evidence about the age of the audience 

If you are thinking that this could be literally anything and this isn’t helpful at all, you aren’t alone. With regard to the content, you create remember that COPPA doesn’t forbid content created for children under the age of 13. It prohibits certain tracking behaviors. So if you make content that falls under one of these prongs as a YouTube creator first you need to make sure to indicate it on the YouTube platform itself.

Next, you need to be aware of what you shouldn’t be doing.

What does COPPA prohibit?

“ You cannot collect information online regarding children (any under 13) through means like passive tracking, requesting, prompting, or encouraging them to submit personal information or enabling a child to make personal information available in an identifiable form” FTC.gov. This is where YouTube got into the shit. YouTube was tracking viewers of ‘children-oriented’ content and serve ads based on tracking behavior. 

If children under the age of 13 are being tracked by cookies like Google Adsense or Facebook pixel then the operator of the website MUST have VERIFIABLE PARENTAL CONSENT. Yuuuppp. This is what YouTube was lacking. However, I think the FTC is really clear that the WEBSITE OPERATOR is the one responsible, that would be YouTube. 

This prohibition on collecting information extends to usernames and screen names. Yes, that means asking viewers to comment is problematic. The first step is understanding your content and making sure it’s clear who it’s intended for. The second step is understanding what you can and can’t do.

What can creators do to protect themselves?

While I think YouTube will continue to try to pass the responsibility to creators it is ultimately YouTube who has the power to stop tracking. What this likely means for creators whose content can be considered child-oriented is that their ad revenue will go down, they will see monetization turned off on some content, they will see comments potentially disabled on some content. We know that engagement drives how videos show up in search and how they are suggested by YouTube so videos will likely be suggested less. Creators need to be ready to ride this out while YouTube figures out how and if they will continue to serve ads on child-oriented content. 

One of the most important things in all of this is that Creators make sure they don’t encourage information to be shared, that means not asking for comments or for engagement that requires a screen name or username to be shared. That they do not host giveaways where there is no age verification to ensure minors under 13 don’t enter. The onus is on YouTube but creators will get thrown under the bus in a second. So be smart, stay informed (you can always follow me on social cause I am not going to stop talking about this anytime soon @theemilydbaker… shameless plug over) and talk to other creators in your space. 

I also have two podcast episodes on this topic, or you can find Get Legit Law & Sh!t in your favorite podcast player.

If you have any questions hit the contact form below, I am here to help.

If you have a community that needs this information I am here to help. Shoot me an email to hello@emilydbaker.com. I am happy to talk to your community, podcast, or channel about how to Get Legit™.

Emily D. Baker, Esq.

Emily D. Baker, Esq.

Badass Lawyer for Online Business

Emily has been running business for 15 years and has ove 13 years of legal experience. She spent 10 years at the Los Angeles County District attorney's office where she truly learned to be a solopreneur. Emily has built her consulting and speaking business from the ground up, in her garage jamming out to 90's music. She specializes in no BS practical advice for the starting and scaling online entreprenur. Emily will tell you what the business gurus can't in a way that is both hillarious and empowering.

Questions for Emily? Just Ask...

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YouTube & Google Fined 170 Million for violating Children’s Privacy Laws

YouTube & Google Fined 170 Million for violating Children’s Privacy Laws

In a historic move, the FTC has fined YouTube and it’s parent company Google 170 Million for violations of the Children’s Privacy Law. Let’s break it down, who is the FTC, what is the Children’s Online Privacy Protection Act (COPPA), WTF did YouTube do to get this much hate and what comes next. 

Now it’s time for a Break Down

1. The FTC

The Federal Trade Commission (FTC) is a federal government agency in the United States who is tasked primarily with consumer protection through stopping ‘unfair, deceptive or fraudulent practices in the marketplace’ -FTC.gov. In the last 10 or more years, the FTC has been really busy regulating online practices, this includes protecting consumer and children’s privacy, regulating advertising practices and regulating how private information may be tracked online. The FTC does this by passing regulations and acts like the Children’s Online Privacy Protection Act (COPPA). 

2. COPPA (not the Cabana)

Which brings us too …what the hell is COPPA. COPPA was enacted in 1998 and is one of the many laws governing how we interact online and it states in part that websites “cannot collect information online regarding children (any under 13) through means like passive tracking, requesting, prompting, or encouraging them to submit personal information or enabling a child to make personal information available in an identifiable form”. www.ftc.gov . There are a substantial number of guidelines in the law which I cover in detail on the Get Legit Law & Sh!t podcast. But know, that the FTC breaks that shit down …all the way.

3. How Did We Get Here?

So why is the FTC salty with Google and YouTube? First, it’s not just the FTC, the state of New York also sued Google & YouTube in this case …but for the sake of being brief, I will continue to just refer to the FTC. The FTC states in their complaint that YouTube violated COPPA by using cookies to track viewers of YouTube channels with child-directed consent. The FTC states that YouTube earned millions of dollars by using these cookies to deliver targeted advertisements to viewers of these channels.

The thing that really pissed off the FTC is the fact that YouTube touted itself as “#1 website regularly visited by kids” and as being “today’s leader in reaching children age 6-11” and by stating to advertisers Mattel and Hasbro essentially that YouTube was the best place to reach kids and was competitive with any TV channel out there. Look, just from my kids’ behavior, I believe all of it. My kids love YouTube, their friends love YouTube and if I don’t buy some merch from Ryan of Ryan’s Toy Review this Christmas my 7-year-old may try to find a new family.

FTC Chairman Joe Simons stated in the agencies press release that “YouTube touted its popularity with children to prospective corporate clients yet when it came to complying with COPPA the company refused to acknowledge that portions of its platform were clearly directed to kids. There’s no excuse for YouTube’s violations of the law”.  

The FTC even included the following images in its press release just to drive home the point that YouTube held itself out as an attractive offering for advertisers based on their access to children. But this isn’t a first for Google. As the image from the FTC shows Google has been fined 258.2 million in fines since 2012 for privacy violations. 

But Wait…There’s More.

In addition to the fines, the fine requires Google and YouTube to develop, implement and maintain a system that permits channel owners to identify their child-directed content on YouTube so that YouTube can ensure that it’s complying with COPPA= and companies must notify channel owners that their child-directed content may be subject to COPPA and provide annual training about complying with COPPA for employees who deal with YouTube channel owers. YouTube also must show that they are obtaining verifiable parental consent before collecting personal information from children.

As of December 12, 2019, YouTube has reached out to the FTC for further guidance to help creators comply with COPPA. Notice how YouTube is shifting the burden of compliance away from the platform and onto creators?? Last time I checked it was YouTube and Google who are in charge of serving ads on creator channels. YouTube is in sole control of what ads are shown and even if ads are shown on a particular channel. Yes, YouTube has made it possible for content creators to state if their content is directed at children, but YouTube has provided little other guidance, so this is an evolving issue and there will be more on this to come! 

Tune in for Get Legit Law & Sh!t next week for my suggestions to creators and all website owners on COPPA compliance and a few other interesting ways the FTC has been cracking down. 

If you have a community that needs this information I am here to help. Shoot me an email to hello@emilydbaker.com. I am happy to talk to your community, podcast, or channel about how to Get Legit™.

Emily D. Baker, Esq.

Emily D. Baker, Esq.

Badass Lawyer for Online Business

Emily has been running business for 15 years and has ove 13 years of legal experience. She spent 10 years at the Los Angeles County District attorney's office where she truly learned to be a solopreneur. Emily has built her consulting and speaking business from the ground up, in her garage jamming out to 90's music. She specializes in no BS practical advice for the starting and scaling online entreprenur. Emily will tell you what the business gurus can't in a way that is both hillarious and empowering.

Questions for Emily? Just Ask...

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